IMPORTER SECURITY RECOMMENDATIONS CUSTOMS-TRADE PARTNERSHIP AGAINST TERRORISM (C-TPAT)

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1 IMPORTER SECURITY RECOMMENDATIONS Develop and implement a sound plan to enhance security procedures throughout your supply chain. Where an importer does not control a facility, conveyance or process subject to these recommendations, the importer agrees to make every reasonable effort to secure compliance by the responsible party. The following are general recommendations that should be followed on a case-bycase basis depending on the company s size introduced into the supply chain. Security controls should include the supervised introduction/removal of cargo, the proper marking, weighing, counting and documenting of cargo/cargo equipment verified against manifest documents, the detecting/reporting of shortages/overages, and procedures for affixing, replacing, recording, tracking, and verifying seals on containers, trailers, and railcars. The movement of incoming/outgoing goods should be monitored. Random, unannounced security assessments of areas in your company s control within the supply chain should be conducted. Procedures for notifying Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected, or suspected, by the company should also be in place. Physical Security: All buildings and rail yards should be constructed of materials which resist unlawful entry and protect against outside intrusion. Physical security should include perimeter fences, locking devices on external and internal doors, windows, gates and fences, adequate lighting inside and outside the facility, and the segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by a safe, caged or otherwise fenced-in area. Access Controls: Unauthorized access to facilities and conveyances should be prohibited. Controls should include positive identification, recording, and tracking of all employees, visitors, and vendors. Procedures should also include challenging unauthorized/unidentified persons. employees including the recognition of internal conspiracies, maintaining cargo integrity, and determining and addressing unauthorized access. These programs should offer incentives for active employee Manifest Procedures: Companies should ensure that manifests are complete, legible, accurate, and Conveyance Security: Conveyance integrity should be maintained to protect against the introduction of unauthorized personnel and material. Security should include the physical search of all readily accessible areas, the securing of internal/external compartments and panels, and procedures for reporting cases in which unauthorized personnel, unmanifested materials, or signs of tampering, are discovered.

2 BROKER SECURITY RECOMMENDATIONS Procedural Security: Companies should notify Customs and other law enforcement agencies whenever anomalies or illegal activities are detected or suspected. Documentation Processing: Brokers should ensure that all information provided by the importer/exporter, freight forwarder, etc., and used in the clearing of merchandise/cargo, is legible and protected against the exchange, loss or introduction of erroneous information. Documentation controls should include: procedures for maintaining the accuracy of information received, including the shipper and consignee name and address, first and second notify parties, description, weight, quantity, and unit of measure (i.e. boxes, cartons, etc) of the cargo being cleared. procedures for recording, reporting, and/or investigating shortages and overages of merchandise/cargo. procedures for tracking the movement of incoming and outgoing goods. procedures to safeguard computer access and information. Education and Training Awareness: A security awareness program should include notification being provided to Customs and other law enforcement agencies whenever anomalies or illegal activities are detected or suspected. These programs should provide: incentives for active employee training in documentation fraud and computer security controls.

3 MANUFACTURER SECURITY RECOMMENDATIONS recommendations that should be followed on a case by case basis depending on the company s size The company should have a written security procedure plan in place that addresses the following: Physical Security: All buildings should be constructed of materials which resist unlawful entry and protect against outside intrusion. Physical security should include: adequate locking devices for external and internal doors, windows, gates, and fences. segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by a safe, caged, or otherwise fenced-in area. adequate lighting provided inside and outside the facility to include parking areas. separate parking area for private vehicles separate from the shipping, loading dock, and cargo areas. having internal/external communications systems in place to contact internal security personnel or local law enforcement police. Access Controls: Unauthorized access to the shipping, loading dock and cargo areas should be prohibited. Controls should include: the positive identification, recording, and tracking of all employees, visitors and vendors. procedures for challenging unauthorized/unidentified persons. Procedural Security: Measures for the handling of incoming and outgoing goods should include the protection against the introduction, exchange, or loss of any legal or illegal material. Security controls should include: having a designated security officer to supervise the introduction/removal of cargo. properly marked, weighed, counted, and documented products. procedures for affixing, replacing, recording, tracking, and verifying seals on containers, trailers, and railcars. procedures for detecting and reporting shortages and overages. procedures for tracking the timely movement of incoming and outgoing goods. proper storage of empty and full containers to prevent unauthorized access. procedures to notify Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected or suspected by the company. employees including recognizing internal conspiracies, maintaining product integrity, and determining

4 WAREHOUSE SECURITY RECOMMENDATIONS CUSTOMS-TRADE PARTNERSHIP AGAINST TERRORISM (C-TPAT) Warehouses as defined in this guideline are facilities that are used to store and stage both Customs bonded and non-bonded cargo. The company should have a written security procedure plan in place addressing the following: Physical Security: All buildings should be constructed of materials, which resist unlawful entry and protect against outside intrusion. Physical security should include: adequate locking devices for external and internal doors, windows, gates and fences. adequate lighting provided inside and outside the facility to include parking areas. segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by a safe, caged, or otherwise fenced-in area. separate parking area for private vehicles separate from the shipping, loading dock, and cargo areas. having internal/external communications systems in place to contact internal security personnel or local law enforcement police. Access Controls: Unauthorized access to facilities should be prohibited. Controls should include: the positive identification, recording, and tracking of all employees, visitors, and vendors. procedures for challenging unauthorized/unidentified persons. introduced into the warehouse. Security controls should include: having a designated security officer to supervise the introduction/removal of cargo. properly marked, weighed, counted, and documented cargo/cargo equipment verified against manifest documents. procedures for affixing, replacing, recording, tracking, and verifying seals on containers, trailers, and railcars. procedures for detecting and reporting shortages and overages. procedures to notify Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected or suspected by the company. proper storage of empty and full containers to prevent unauthorized access. employees including recognizing internal conspiracies, maintaining cargo integrity, and determining

5 AIR CARRIER SECURITY RECOMMENDATIONS Conveyance Security: Aircraft integrity should be maintained to protect against the introduction of unauthorized personnel and material. Conveyance security procedures should include the physical search of all readily accessible areas, securing all internal/external compartments and panels, and reporting cases in which unmanifested materials, or signs of tampering, are discovered. Access Controls: Unauthorized access to the aircraft should be prohibited. Controls should include the positive identification, recording, and tracking of all employees, visitors and vendors as well as procedures for challenging unauthorized/unidentified persons. introduced aboard the aircraft. Security controls should include complete, accurate and advanced lists of international passengers, crews, and cargo, as well as a positive baggage match identification system providing for the constant security of all baggage. All cargo/cargo equipment should be properly marked, weighed, counted, and documented under the supervision of a designated security officer. There should be procedures for recording, reporting, and/or investigating shortages and overages, and procedures to notify Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected or suspected by the carrier. Manifest Procedures: Companies should ensure that manifests are complete, legible, accurate, and employees covering the recognition of internal conspiracies, maintaining cargo and baggage integrity, and determining and addressing unauthorized access. These programs should offer incentives for active employee Physical Security: All buildings, warehouses, and on & off ramp facilities should be constructed of materials, which resist unlawful entry and protect against outside intrusion. Physical security should include adequate locking devices for external and internal doors, windows, gates and fences. Perimeter fencing should also be provided for, as well as adequate lighting inside and outside the facility, to include parking areas. There should also be segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by a safe, caged or otherwise fenced-in area.

6 SEA CARRIER SECURITY RECOMMENDATIONS Conveyance Security: Vessel integrity should be maintained to protect against the introduction of unauthorized personnel and material. Conveyance security should include the physical search of all readily accessible areas, the securing all internal/external compartments and panels, and procedures for reporting cases in which unmanifested materials, or signs of tampering, are discovered. Access Controls: Unauthorized access to the vessel should be prohibited. Controls should include the positive identification, recording, and tracking of all employees, visitors, and vendors and procedures for challenging unauthorized/unidentified persons. introduced aboard the vessel. Security procedures should provide for complete, accurate and advanced lists of crews and passengers. Cargo should be loaded/removed under supervision of a designated security officer and shortages/overages should be detected and reported appropriately. There should also be procedures for notifying Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected, or suspected, by the company. Manifest Procedures: Companies should ensure that manifests are complete, legible, accurate and employees including recognizing internal conspiracies, maintaining cargo integrity, and determining Physical Security: All buildings should be constructed of materials, which resist unlawful entry and protect against outside intrusion. Physical security should include adequate locking devices on external and internal doors, windows, gates, and fences. Plans should also address perimeter fencing, adequate lighting inside and outside the facility, and the segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse/terminal area by a safe, caged or otherwise fenced-in area.

7 LAND CARRIER SECURITY RECOMMENDATIONS Conveyance Security: Integrity should be maintained to protect against the introduction of unauthorized personnel and material. Conveyance security procedures should include the physical search of all readily accessible areas, securing all internal/external compartments and panels, and procedures for reporting cases in which unmanifested materials, or signs of tampering, are discovered. Physical Security: All buildings and rail yards should be constructed of materials, which resist unlawful entry and protect against outside intrusion. Physical security should include adequate locking devices on external and internal doors, windows, gates and fences. Perimeter fencing should be addressed, as well as adequate lighting inside and outside the facility, to include the parking areas. There should be segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by a safe, caged or otherwise fenced-in area. Access Controls: Unauthorized access to facilities and conveyances should be prohibited. Controls should include the positive identification, recording, and tracking of all employees, visitors, and vendors as well as procedures for challenging unauthorized/unidentified persons. introduced aboard the conveyance. Security controls should include the proper marking, weighing, counting, and documenting of cargo/cargo equipment under the supervision of a designated security officer. Procedures should be in place for affixing, replacing, recording, tracking, verifying seals on containers, trailers, and railcars, and a system for detecting and reporting shortages and overages. The timely movement of incoming and outgoing goods should be tracked and there should be procedures for notifying Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected or suspected by the company. Manifest Procedures: Companies should ensure that manifests are complete, legible, accurate, and employees including recognizing internal conspiracies, maintaining cargo integrity, and determining